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Re: 700 cancer cases caused by X-rays...Montclair NJ info...







        Bill, the outcome was the removal of the vast majority of  Ra-226 

contaminated soils from over 175 properties (along with a small component Th-232 

probably used when the facilty switched to Mesothorium in the belief that it 

would be less hazardous) . The material involved was actually a process sand 

that was freely dumped after Radium refinement from material that lacked 

Radium's parental  precursors ( only in one small area was Rn found in equilibrium 

with its U parent) .The actual disputes as I understood them, did not involve 

local landfills, but waste transportation and its' acceptence by another state. 

Nobody wanted New Jersey's contaminated garbage nor would they allow it to 

pass through their backyard (the anti's had a field day with this). This 

neccessitated the current USEPA involvement as the NJDEP and the state of NJ did not 

have the political horsepower to get the soil moving. The various horror 

stories many may have heard date from that time when the NJDEP began remediation 

with out securing the guarantees for disposal (eg homeowners out of their homes 

for years, placarded barrels piled ten high, techs surveying rocks for free 

release etc...). As for the book, it is well researched  dry read of which I keep 

a copy on my desk.

    John, your conclusions are incorrect. The spectroscopic analysis of the 

soils from the Montclair Superfund Project irrefutably contradict your 

conclusions. It is pointless to go over that any further.  In several instances, the 

DOE's  4' soil barrier method was tried and abandoned as it was found to have 

only temporarily reduced Rn-222 gas entry into the residences - over time the 

levels returned as pathways were formed in response to the negative pressure 

environment of a basement ( sealing is a poor method of mitigation and in this 

instance, a very expensive one). Additionally, I cannot imagine short lived 

RDP's as a "source of contamination".



    As for the action levels stated  in the Record Of Decision (ROD) when the 

EPA assumed responsibiltiy for the project, they were the good ol'  tried and 

true 5 and 15's (pCi/g)  OR interior Rn greater than 4 pCi/l. The vast 

majority of remedial actions involved violations of the former criterion with the 

latter being the recipients of a sub-slab mitigation system ( which was quite 

effective at 20 pCi/l and certainly not $20,000). At no point was soil removed 

solely to lower Rn-222 levels, except for the few soil barrier method test 

homes (which as discussed earlier, proved largely fruitless). It should be stated 

that very few homes exhibited elevated interior Rn levels to begin with, and 

of those, all but 1 or 2 sat upon significant deposits of  the waste stream  

with activities in the 20 500 pCi/g range (Ra-226). The inclusion of the Rn 

component in the ROD at all was, as I suspect, a way of trying to put a friendlier 

face on the project. It always was a misnomer to call it a Radon remediation, 

but that is what it is generally referred to as by the locals. Rn was a 

problem that other homeowners elsewhere faced and it was after all "natural" ( one 

didn't need to live on a superfund site to have it). You could feel the 

increased level of fear in someone if the term was radioactive Radium  as opposed to 

Radon. People already had preconceived notions about Radon and would 

generally not seem as interested in continued scientific discussions concerning nature 

of their contamination as they felt it a somewhat known commodity. This also 

had the nice fit with the rest of the USEPA's new initiative on Rn at that 

time.



 Now finally, to the 4 pCi/l threshold I hear so much about on the list.  

This number as I understand it, like a lot of other regulatory numbers, relates 

only to ALARA ( reasonable is  subjective by definition). The EPA has discussed 

reducing that level to 2 pCi/l - not because they believe  that is the level 

at which it is now safe -  but because they believe the vast majority of homes 

test in at significantly below this level, because they believe it is a 

number that can be readily detected, and because they believe it is a level which 

can be obtained without obtuse difficulty. There is no apparent epidemiological 

basis upon which these levels rest. The EPA subscribes to LNT, and as long as 

they do, they will continue to want all exposures reduced to as close to zero 

as possible. I personally doubt the efficacy of the extrapolations upon which 

LNT is based, nor do I have blind faith in  regulatory simplifications 

inherent in dose assessment, but I cannot as yet, find demonstrable proof to refute 

them.



David Lawrence

Eberline Services

Montclair, NJ



These opinions are mine and definitely NOT THOSE OF MY EMPLOYER